JOFOC TPM extension 2026 7.29 package - CFO Signed_Redacted.pdf

• Facilitate beneficiary access to Employment Networks (ENs);

• Recruit experienced and highly qualified ENs;

• Assist SSA in facilitating and monitoring active EN participation in the Ticket Program;

• Facilitate the Ticket assignment and EN and State Vocational Rehabilitation (VR) Agencies (SVRA)payment processes;

• Assist the Social Security Administration (SSA or Agency) to ensure the quality and integrity of EN Ticket services; and

• Coordinate and merge into a seamless effort all beneficiary and EN marketing, outreach, training, support, and performance monitoring

AFS is the only contractor at this time who can perform the work while the agency takes corrective action as a result of the protest, and it is essential that work continue on TPM without a break in service.

3. DESCRIPTION OF SUPPLIES/SERVICES AND ESTIMATED VALUE

Estimated Value: $5,900,000

The Ticket to Work and Work Incentives Improvement Act of 1999 requires SSA to use an external TPM to help administer the Ticket to Work (TTW) Program. 42 U.S.C. § 1320b- 19(d). The Ticket Program provides disability beneficiaries with more options for employment services while increasing provider incentives to serve these individuals. The Ticket Program directs SSA to provide disability beneficiaries with a Ticket that they may use to obtain state VR services, employment services, and/or other support services from an EN of their choice and establish agreements with ENs to provide such services.

There are five major components of the Ticket Program.

1. Consumer Options for Employment Services The Ticket enables Social Security Disability Insurance (SSDI) and Supplementary Security Income (SSI) beneficiaries to work with a participating EN or they may seek services from a SVRA. The process of choosing an EN is called Ticket assignment.

Beneficiaries may seek services from SVRAs that either act as ENs or provide services to SSDI and SSI beneficiaries with disabilities under the traditional VR reimbursement option. If the SVRA elects to provide services under the traditional VR cost reimbursement option, the beneficiary does not assign the Ticket to the EN, although SSA considers the Ticket as being “in use” for program purposes (see below). In addition, a beneficiary may choose to receive up-front services from a SVRA, and then choose to receive continuing services from an EN.

2. Increased Choices for Employment Services Through Employment Networks An EN is an organizational entity (State or local, public or private) that enters into an agreement with SSA to assume responsibility for the coordination and delivery of appropriate employment services, VR services, or other support services under the Ticket Program to beneficiaries who have assigned Tickets to the EN. SVRAs also may elect to function as an EN under the Ticket Program.

An EN may be either a single provider of such services or an association of providers organized to combine their resources into a single entity. An EN may provide services necessary to prepare and place beneficiaries in employment, either directly or by entering into agreements with other providers of such services.

Under the Ticket program, a beneficiary whose Ticket-eligibility is established by SSA, may “assign” that Ticket to any EN of the beneficiary’s choice that is serving under the Ticket Program and is willing to accept the assignment.

3. Provider Payment Options An EN that accepts Tickets from beneficiaries, and SVRAs that act as ENs, must select one of the two payment plans, as follows:

Outcome payment system (Outcome): An outcome payment is an amount up to 67 percent of the average SSDI benefit for every month up to 36 months that the SSDI or concurrently entitled beneficiary is not due cash benefits because of his or her work or earnings, or an amount up to 67 percent of the average SSI monthly benefit for every month up to 60 months that the SSI beneficiary is not due cash benefits because of his or her work or earnings; or

Outcome-milestone payment system (Milestone): Milestone payments are made in two phases. In Phase 1, SSA may pay milestone payments based on a beneficiary’s achievement of work and earnings, with up to four payments within an 18-month period.

In Phase 2, SSA may pay up to 11 milestone payments resulting from an SSDI beneficiary’s achievement of work and earnings, and up to 18 milestone payments for an SSI beneficiary’s achievement of work and earnings.

As explained earlier, SVRAs that choose to provide services to Ticket-holders under the traditional State VR program receive reimbursement for the costs of the services provided.

4. Suspension of Continuing Disability Reviews (CDRs) By law, SSA must periodically reassess all beneficiaries receiving benefits based on disability to determine if they continue to meet medical requirements for disability benefits (i.e., if they continue to be so impaired that the beneficiaries would reasonably be considered unable to perform substantial work). If after a medical CDR SSA determines that a beneficiary has had medical improvement in his or her impairments and that the medical improvement is related to the ability to work at the Substantial Gainful Activity (SGA) level, then SSA must cease the beneficiary’s disability cash benefits. When a beneficiary is “using the Ticket,” SSA defers any scheduled medical CDR that has not begun before the beneficiary began to use the Ticket. SSA considers the Ticket to be “in use” if assigned to an EN or to an SVRA being paid as an EN, or “in-use SVR” if the beneficiary is working with an SVRA under traditional cost reimbursement.

5. Role of the Program Manager Public Law 106-170 (codified at 42 U.S.C. § 1320b-19(d)) requires the Commissioner of Social Security Administration to enter into an agreement(s) with a Program Manager(s) (PM) to assist in administering the Ticket Program. While the PM may be tasked with a wide range of duties, the following four responsibilities are identified specifically in the law:

• Recruitment and monitoring of ENs,

• Ensuring the availability of a sufficient number of ENs,

• Ensuring the availability of adequate EN services to beneficiaries, and

• Facilitation of beneficiary access to ENs.

The law precludes the PM from direct participation in the delivery of employment services, VR services or other support services to beneficiaries in the service area covered by the PM’s agreement. In addition, the PM shall not hold a financial interest in an EN or service provider that provides services in a geographic area covered under the PM’s agreement.

4. IDENTIFICATION OF STATUTORY AUTHORITY PERMITTING OTHER

THAN FULL AND OPEN COMPETITION

The statutory authority permitting other than full and open competition is 41 U.S.C. § 3304(a)(2) which states “the executive agency's need for the property or services is of such an unusual and compelling urgency that the Federal Government would be seriously injured unless the executive agency is permitted to limit the number of sources from which it solicits bids or proposals.” The regulatory authority permitting other than full and open competition is Revolutionary FAR Overhaul (RFO) Part 6.103-2 Unusual and compelling urgency.

The agency’s need for these services is of such an unusual and compelling urgency that the Federal Government would be seriously injured unless the agency is permitted to restrict competition. It is imperative that SSA immediately continue uninterrupted operations of the Ticket to Work (TTW) program to ensure compliance with statutory requirements, specifically Public Law 106-170/42 U.S.C. § 1320b-19. Failure to proceed immediately with these essential services would essentially suspend the TTW program, place the Agency in direct violation of federal law, restrict beneficiary access to critical services, thus exposing SSA to significant legal and reputational risks.

One critical task under the TTW program is maintaining the websites. Discontinuation of the TTW websites would severely impact financially both beneficiaries seeking to participate or currently engaged in the program, as well as ENs that provide critical support. The loss of this online resource would eliminate a primary channel for information, guidance, and enrollment, effectively halting the program’s accessibility and outreach. Moreover, cessation of the TTW helpline would leave beneficiaries and ENs without a dedicated support mechanism, resulting in unanswered questions and unmet needs. A gap in service would likely overwhelm SSA’s national 800 number, inundating agents with inquiries they are not equipped to handle. This would diminish overall customer service and increase wait times for all callers.

Another significant part of the services provided include the beneficiary contact center, known as the Ticket to Work Help Line. The Help Line receives on average approximately 375 calls per day. If Help Line call traffic ceases, those calls will move to SSA’s national

800 number. Not only will this increase the burden on the national 800 number, but the agents will not be able to answer the TTW specific questions, thus jeopardizing beneficiary’s return to work efforts, which ultimately impacts their financial state and self-sufficiency.

TPM services also include processing payments for the ENs. The contractor is responsible for ensuring that ENs are properly compensated for the work milestones and outcomes achieved by beneficiaries in the Ticket Program, and that payments are made in a timely, accurate, and efficient manner. The contractor receives payment requests, reviews them to ensure proper evidence of services is provided, validates earnings data, and submits the requests to SSA for payment. SSA does not have the capacity to assume this responsibility.

As a result, payments to ENs, who play a critical role in supporting beneficiaries seeking to return to work and leave the disability rolls, would be significantly delayed, thus creating a financial hardship on ENs.

Ultimately, the primary goal of the TTW program is to help beneficiaries receiving disability benefits achieve gainful employment, leading to self-sufficiency and independence from those benefits. To support this mission, the contract includes critical outreach efforts designed to expand the program and reach more beneficiaries. If these services are interrupted, all outreach activities will cease, halting program growth and undermining the Agency’s ability to fulfill its objectives

Finally, the urgency of maintaining operations of the TTW program to support the Agency and the beneficiaries it serves is evidenced in both referenced contracts (i.e., the protested contract (28321326C00060006) and the contracting being extended (28321321C00060001), both of which include an optional transition-out task to ensure uninterrupted services in the event a new contractor was selected.

5. DEMONSTRATION OF CONTRACTOR'S UNIQUE QUALIFICATIONS

On June 30, 2026, SSA awarded contract number 28321326C00060006 for TPM services to the incumbent contractor, AFS, after a competitive award process. AFS’ existing contract also expired on this date and as noted above, there are no extensions remaining under FAR 52.217-8 “Option to Extend Services.” On July 13, 2026, the CO received a protest requiring a stay of performance under the new contract. It is critical that work continue while the Agency takes corrective action as a result of this protest. Performance under the new contract must stop immediately, but work must continue. There is an urgent need to continue services immediately and AFS is the only entity in a position to provide these immediate services.

As noted above, the TPM contract provides important disability beneficiary services by offering more options for employment services while increasing provider incentives to serve these individuals. It is vital that these services continue without interruption.

AFS has the unique ability to perform TPM services starting immediately because they currently provide these services and have been doing so since 2021. They are experienced with all aspects of the TPM program including:

• SSA’s beneficiary call center operations and helpline;

• Ticket program website and ticket assignment and management;

• Beneficiary outreach, management, and dispute resolution;

• Employment Network (EN) recruitment, training, payment administration, quality review, and audit services.

In addition, as the incumbent AFS has trained staff, systems, processes, and facilities currently in place to support the immediate need. While it is possible for another contractor to perform this work, the hiring, establishing a call center, training on SSA specific procedures, obtaining security authorizations for systems, and onboarding staff would take up to three months. AFS is the only contractor in the position to continue these urgent and critical services. Additionally, given the nature of the need for this extension in that it resulted from a protest of a full and open competition, it is not reasonable to compete this extension. For these reasons, AFS is the only source capable of providing continued service for the TPM contract.

6. DESCRIPTION OF EFFORTS MADE TO SOLICIT FROM AS MANY

POTENTIAL SOURCES AS IS PRACTICABLE

The solicitation for the award being protested was posted to SAM.gov and was a full and open competition. In accordance with the Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO) 5.101(b)(2) this action is exempt from publication to the Government Point of Entry.

7. DETERMINATION BY THE CO THAT THE ANTICIPATED COST TO THE

GOVERNMENT WILL BE FAIR AND REASONABLE

In accordance with RFO Part 15.404-2, the CO will perform a final cost analysis in order to determine the eventual awardee’s proposed cost is fair and reasonable.

8. DESCRIPTION OF MARKET RESEARCH

This action is needed as a result of protest of a competitive acquisition. Market research is not necessary since due to the competitive nature of the acquisition, data about the market is already available to the CO. In accordance with RFO 4.203-2(a), based on the market data obtained through the competitive process, the CO has concluded that there are no other sources with the infrastructure in place to support this immediate and urgent need.

9. ANY OTHER SUPPORTING FACTS

In accordance with RFO 4.203-2(a)(1) and 9.103, the CO will examine the System for Award Management in order to make an affirmative determination of the contractor’s responsibility.

10. LIST OF SOURCES EXPRESSING INTEREST IN THE ACQUISITION IN

WRITING

N/A – Due to the urgent nature of this requirement, it was not posted to the GPE.

11. ACTIONS AGENCY MAY TAKE TO REMOVE OR OVERCOME BARRIERS TO

COMPETITION BEFORE ANY SUBSEQUENT ACQUISITION IS REQUIRED

SSA plans to award a new TPM contract for continued services once procurement is complete.